January 19, 2011
Mr. Russell Kirkham
Department of Natural Resources
550 W 7th Ave Ste 290
Anchorage, AK 99501
Re: Petition to Designate the Chuit River Watershed as Unsuitable for Surface Coal Mining
Dear Mr. Kirkham:
The Resource Development Council for Alaska, Inc., (RDC) urges you to reject the petition filed by Trustees for Alaska on behalf of Chuitna Citizens Coalition and Cook Inletkeeper to designate the Chuit River watershed unsuitable for coal mining.
RDC is a statewide business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
This is the Petitioners’ second request to designate the area unsuitable for coal mining. The Petition filed in July 2007 was deemed incomplete and rejected by the Commissioner. Apart from minute details and a narrower scope of the area to be designated, the current petition is nearly identical to and contains the same arguments as the rejected one.
The Chuit River watershed lies in the area now covered by the State Kenai Area Plan. Area planning is a management tool used by the Department of Natural Resources that involves extensive public input. The Kenai Area Plan was developed over an eight-year period and included four rounds of public comment, and public meetings in six communities, including Tyonek and Beluga. The final plan concluded that the highest value use for the Chuit River lands was coal development, and specifically addressed coal development in the petitioned area.
PacRim Coal, LP assumes a responsibility of operating under the Alaska Surface Coal Mining Control and Reclamation Act (ASCMCRA) and employing the most advanced mining practices and environmental standards possible. The Petition alleges that these standards will not be met. If this were true, a permit would not be issued and the mine would not be allowed to operate. PacRim has not only committed to adhering to the highest environmental standards, but has also submitted improvements to current habitat designed in collaboration with area stakeholders.
In its request to intervene in the Petition, Tyonek Native Corporation (TNC) states its support for responsible coal development in the area. TNC has engaged in efforts to increase local employment opportunities for its shareholders, who comprise the majority of the area’s population. The corporation states that developing the Chuitna coal resources is critical to economic growth and would attract shareholders living outside the region to return, should jobs be available for them. This local support from Alaska Native people refutes the Petition’s claim that development activities will damage cultural values in the region.
In its intervention in the Petition, the Alaska Mental Health Trust Authority Trust Land Office (TLO) asserts its position as lessor of lands in the area subject to the Petition. TLO receives annual lease payments during the exploration stage, and should production occur, an estimated $300 million in royalties could be collected to benefit mental health programs in Alaska. Designating the lands as Unsuitable to Mining would affect land specifically conveyed to the TLO for its potential coal and mineral value.
RDC urges you to reject the Petition to designate the Chuit River watershed as Unsuitable for Coal Mining. PacRim should be allowed the opportunity to navigate the State’s thorough permitting process, and at the time a mine plan is submitted, the Petitioners will be given ample opportunity to provide input.
Thank you for the opportunity to provide comments on this important issue.
Resource Development Council for Alaska, Inc.